The programs I've been involved with did not have anything to do with the FCC.  Sounds like they have more technical competency than some other agencies....and that's a good thing.

On 4/6/2020 4:40 PM, Eric Muehleisen wrote:
No persistence. We objected and they sent someone out almost immediately. This was during CAFII. I assume RDOF will be the same. I've yet to hear of anyone actually providing validation testing. I know the FCC has a couple different methods of remote validation but I haven't seen it personally. We only tested it as a proof of concept prior to the auction. Just be aware that you might get a knock from the FCC who want to test on your network.

On Mon, Apr 6, 2020 at 3:31 PM Adam Moffett <dmmoff...@gmail.com <mailto:dmmoff...@gmail.com>> wrote:

    I'm glad they came out and checked.  You're probably a more
    believable witness than some Internet customers are. How
    persistent did you have to be to get someone to come out?


    On 4/6/2020 4:25 PM, Eric Muehleisen wrote:
    The FCC won't drive around and test themselves, but they will
    follow you as you drive around and test. We disputed several
    locations that had won CAF2 and the FCC sent out two contractors
    to come out and verify our speeds/claims. We spent 2-3 hours with
    them one morning testing in various locations. The FCC will also
    test on network with a Sam Knows whitebox (UK based business).
    Calix also has testing methods that report to FCC as well. We
    haven't tested that method yet.

    On Mon, Apr 6, 2020 at 3:10 PM Adam Moffett <dmmoff...@gmail.com
    <mailto:dmmoff...@gmail.com>> wrote:

        The company owner/administrator talking to the government
        either believes the incorrect assumptions or is wholly
        committed to the lie.  So they confidently report that
        they're delivering 25 Meg like they're supposed to.  Evidence
        to the contrary is a fluke or an error.  The FCC isn't going
        to drive around and speedtest your customers.  The source of
        information saying you're not delivering 25meg is going to be
        a disgruntled customer who is aware that you have grant
        funding, knows what your requirements were, and knows which
        agency to complain to.  There will be very few of those, and
        it's easy to defend yourself from one complainer by simply
        saying /they're/ the crazy/wrong one.

        There will be financial audits, and in some programs there
        are /physical///audits to make sure you bought the things you
        say you did and didn't buy yourself a Ferrari instead.  I'm
        sorry to say that people can and do get away with the
        lie/wrongness about performance.


        On 4/6/2020 3:42 PM, Dev wrote:
        But seemingly, if everyone’s lying, won’t the FCC/etc. come
        down hard in response? Example A: 477’s, where many I’ve
        seen have a fabrication factor, sometimes a very high one.

        On Apr 6, 2020, at 12:13 PM, Adam Moffett
        <dmmoff...@gmail.com <mailto:dmmoff...@gmail.com>> wrote:

        I've seen a number of grant funding proposals based on 25M
        and 100M speeds.

        In general what they do is lie.  Or they're wrong.

        First you use the capacity planning tool provided the
        manufacturer and remember that you can populate the values
        however you want to.  Your prediction doesn't have to be
        perfectly correct, it just has to be defensible if you're
        questioned about it.

        Also use an 8:1 oversubscription ratio and in your
        narrative claim that this is "conservative".  It /was /a
        conservative value in the pre-Netflix world so this is
        another one where they might truly believe it, or they
        could be lying.

        You can also play games with coverage maps.  What's the
        minimum MCS to get a subscriber at 25meg?  Use that signal
        level to predict coverage.  Most of us will realize that at
        that signal you can only have ONE person at 25meg, but
        using that figure makes it a hell of a lot easier to show
        coverage in the entire funding area.

        Whether this is actually a lie, or whether they truly
        believe this stuff is not always obvious to me.  Some of
        them I'm certain think it's true, and I think it's a case
        where their engineering was informed by the equipment sales
        channel.  Others I think are just full of crap, but they
        know what they can get away with.

        I'm not advocating any of these "design choices", but I'm
        telling you these are things people often do to make their
        grant funding applications look defensibly acceptable.  In
        some cases I do believe the applicant is simply wrong. 
        They're an administrator or a business person and they're
        just asking the wrong questions.  Some of them could be
        liars, but you'll note that each of these lies leaves the
        person with the ability to point their finger at someone
        else and say "well that guy told me this equipment could do
        that."

        In the case of NY State, they had an independent
        engineering firm review the proposals for their technical
        plausibility and apparently those guys would look at these
        applications and not see any problem.  I didn't quite
        figure out why that was.....but I have some guesses.

        My info comes from participating in application processes
        and talking to other applicants about what they're doing.

        -Adam


        On 4/6/2020 2:27 PM, Dev wrote:
        So if I understand we’ll have to provide 25/3 to ALL locations that 
receive RDOF funding? If so, how would that happen without the 6GHz that isn’t 
out yet and won’t be by the time this round funds?
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